lback, Epstein alleges without explanation that Edwards "should have known" about the existence of this concealed Ponzi scheme. For example, in his Complaint Epstein alleges: "Upon information and belief, Edwards knew or should have known Rothstein was utilizing RRA as a front for the massive Ponzi scheme . . . .

As the Court has recognized at prior hearings, the issue of Epstein's probable cause is determined in part by the allegations contained within the Complaint Epstein filed against Edwards. Therefore, as Epstein concedes, Edwards will be permitted to put forth witnesses who have personal knowledge of facts and ci